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Court: US Court of Appeals for the Fourth Circuit
Docket:
22-4656
Opinion Date: February 16, 2024
Judge:
WILKINSON
Areas of Law:
Communications Law, Criminal Law, Internet Law
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In a case before the United States Court of Appeals for the Fourth Circuit, six men affiliated with the transnational criminal organization MS-13 were convicted of sex trafficking a thirteen-year-old girl by force, fraud, or coercion, and conspiracy to do the same. The accused appealed the district court’s denial of their motions to suppress evidence obtained from Facebook warrants, arguing the warrants failed the probable cause and particularity requirements of the Fourth Amendment. One of the accused also appealed the district court’s denial of his motion for acquittal, contending that the evidence presented at trial was insufficient to sustain his conviction.
The court held that the Facebook warrants were supported by probable cause, as they were based on substantial evidence linking the accused’s use of Facebook to their criminal activities. The court also held that the warrants were sufficiently particular as they identified the items to be seized by reference to the suspected criminal offenses and confined the officers’ discretion by restricting them from rummaging through the accused’s social media data in search of unrelated criminal activities. However, the court noted that future warrants enhance their claims to particularity by requesting data only from the period of time during which the defendant was suspected of taking part in the criminal conspiracy.
The court rejected one appellant's sufficiency challenge to his conviction and affirmed his convictions, finding that substantial evidence supported the jury’s conclusion that he was guilty of conspiracy to engage in sex trafficking of a minor under fourteen or of a minor by force, fraud, or coercion, and of conspiracy to transport a minor in interstate commerce with intent for the minor to engage in prostitution or illegal sexual activity.
Therefore, the court affirmed the judgment of the district court in all respects.
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